EFTA00224896.pdf
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I . S. Department of .Imtice
United States Attorney
Southern District ofFlorida
500 South Australian Ave . Suite 400
West Palm Beach, FL 3340/
(361)820-8711
Facsimile: (561) 820-8777
September 12,2008
Ms.
via electronic mail
Re: Jeffrey Epstein NOTIFICATION OF
IDENTIFIED VICTIM
Dear Ms. an:
By virtue of this letter, the United States Attorney's Office for the
Southern District
of Florida provides you with the following notice because you are
an identified victim of a
federal offense.
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Eps
tein) entered a plea
ofguilty to violations ofFlorida Statutes Sections 796.07 (felony
solicitation ofprostitution)
and 796.03 (procurement ofminors to engage in prostitution), in
the 15th Judicial Circuit in
and for Palm Beach County (Case Nos. 2006-cf-00945
4AXXXMB and 2008-cf-
009381A)OOCMB) and was sentenced to a term of twelve
months' imprisonment to be
followed by an additional six months' imprisonment, follow
ed by twelve months of
Community Control I, with conditions of community confineme
nt imposed by the Court.
In light of the entry of the guilty plea and sentence, the
United States has agreed to
defer federal prosecution in favor of this state plea
and sentence, subject to certain
conditions, including the following:
I. An independent Special Master was assigned the task
of selecting an
attorney representative to represent the victims,
including you, in
connection with civil actions between the victims and
Mr. Epstein. The
Special Master selected Robert Josefsberg. Esq. of the
firm Podhurst
Orseck, P.A., a highly-respected and experienced attorn
ey. You are not
obligated to use Mr. Josefsberg as your civil attorney,
but, as explained
EXHIBIT B-91
EFTA00224896
MS.
NOTIFICATION OF IDENTIFIED VICTIM
SEPTEMBER I2, 2008
PAGE 2 OF 3
in greater detail below, Mr. Josefsberg's services will be provided at no
cost to you because Mr. Epstein is obligated to pay the costs and fees
of the attorney-representative. Also, Mr. Epstein and his attorneys can
only contact you via Mr. Josefsberg, assuming that you would like Mr.
Josefsberg to serve as your attorney.
2. If you elect to file suit against Mr. Epstein pursuant to Title 18, United
States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
of the United States District Court for the Southern District of Florida
over his person and/or the subject matter, and Mr. Epstein waives his
right to contest liability and also waives his right to contest damages up
to an amount as agreed to between you and Mr. Epstein, so long as you
elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
other claim for damages, whether pursuant to state, federal, or common
law. Notwithstanding this waiver, Epstein's agreement with the United
States, his waivers and failure to contest liability and such damages in
any suit are not to be construed as an admission of any criminal or civil
liability.
3. As stated above, Mr. Epstein has agreed to pay the fees of the attorney
representative selected by the independent third party. This provision,
however, shall not obligate Epstein to pay the fees and costs of
contested litigation filed against him. Thus, if after consideration of
potential settlements, you and Mr. Josefsberg elect to file a contested
lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
contested remedy, the obligation to pay the costs of the attorney
representative, as opposed to any statutory or other obligations to pay
reasonable attorneys fees and costs such as those contained in Section
2255, shall cease.
Mr. Josefsberg will be contacting you within the next two
weeks to explain these
terms. If you would like to contact Mr. Josefsberg directly,
he can be reached at 305 358-
2800.
If you have already selected other counsel to
represent you, or if you do so in the
future, and you decide to file a claim against Jeffrey
Epstein, Mr. Epstein's attorney, Jack
Goldberger, asks that you have your attorney contact Mr.
Goldberger at Atterbury Goldberger
EFTA00224897
Ms. JENNIFER
NOTIFICATION OF IDENTIFIED VICTIM
SEPTEMBER 12,2008
PAGE 3 OF 3
and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
659-8300.
In addition, there has been litigation between the United States and two other victims
regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
to represent you, that attorney can review the Court's order in the matter ofIn re Jane Does
I and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
Investigation can take part in or otherwise assist in civil litigation.
Thank you for all ofyour assistance during the course of this investigation and please
accept the heartfelt regards ofmyselfand Special Agents Kuyrkendall and Richards for your
health and well-being.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
By:
ASSISTANT U.S. ATTORNEY
cc: Robert Josefsberg, Esq.
Jack Goldberger, Esq.
EFTA00224898
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